Tuesday, December 24, 2013

Jones v. Lee case brief

Jones v. Lee case brief summary
971 P.2d 858 (1998)

CASE SYNOPSIS
Appellant buyers challenged the judgments of the District Court of Bernalillo County (New Mexico) that awarded compensatory and punitive damages to appellee sellers in their breach of contract action against appellants and compensatory damages to appellee broker-agents based on appellants' breach of a contract to purchase realty.

CASE FACTS
Appellant buyers entered into a written real estate contract but failed to consummate the agreement. Appellee sellers filed suit for breach of the purchase agreement, appellant filed counterclaims against appellee sellers and appellee broker-agents, and appellee broker-agents filed a counterclaim for the commission. The district court dismissed appellants' counterclaims and entered judgment in favor of appellee sellers for $ 157,118.94 which included the difference between the contract price and the actual sale price, assorted special damages, punitive damages, costs and prejudgment interest; and judgment in favor of appellee broker-agents for the commission and attorney fees. Appellants challenged the calculation of compensatory damages and the special damages.

DISCUSSION

  • The court reversed and remanded for the district court to calculate the loss of bargain, which was the difference between the purchase price and the market value of the property at the time of the breach. 
  • The special damages that were contemplated and that were the ordinary and natural consequences of the breach were appropriate, and there was evidence to support punitive damages.

CONCLUSION
The court reversed and remanded for the district court to calculate the loss of bargain, which was the difference between the purchase price and the market value of the property at the time of the breach. The special damages that were contemplated and that were the ordinary and natural consequences of the breach were appropriate, and evidence existed to support an award of punitive damages.


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